What is Even Hotels required to do regarding consumer consents for services offered by FreedomPay?

According to Even Hotels' 2025 Franchise Disclosure Document, the franchisee (Hotel) is responsible for obtaining all necessary consumer consents related to any services provided by FreedomPay, including third-party services, as mandated by law. This means that Even Hotels franchisees must ensure they are compliant with all applicable legal requirements regarding consumer data privacy and consent when using FreedomPay's services.

In practical terms, this places the onus on the Even Hotels franchisee to understand and adhere to relevant data protection laws, such as GDPR or CCPA, depending on the location of their hotel and the consumers they serve. They will need to implement procedures for obtaining and documenting consumer consent for data collection, usage, and sharing related to FreedomPay's services. This may involve updating privacy policies, implementing consent forms, and providing consumers with clear and accessible information about how their data is being used.

The FDD highlights that IHG will process the onboarding of the Hotel, administer payments related to the Next-Gen Payments Solution, and facilitate support for Hotel, FreedomPay is the provider of the payment gateway services. The payment of fees and requests for service, and other interaction with FreedomPay will be routed through IHG, acting as a facilitator. Hotel will direct requests for service to IHG. This means that Even Hotels franchisees will need to work closely with IHG to ensure compliance and may need to seek legal counsel to ensure they fully understand their obligations.

Failure to obtain proper consumer consents could result in legal penalties, damage to the Even Hotels brand's reputation, and loss of consumer trust. Therefore, it is crucial for prospective Even Hotels franchisees to carefully consider the implications of this responsibility and ensure they have the resources and expertise to meet these requirements.